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4 Answers

Adding a class or category?

Asked by: 11209 views Commercial Pilot, Helicopter, Instrument Rating

I currently enjoy the privileges of: Rotorcraft/Helicopter-Private, Single Engine-Private, Instrument-Airplane, Multi Engine-Commercial (received in that order). I am currently working on adding: Instrument-Helicopter. If I am interpreting FAR 61.63 (c) correctly, I am not required to meet the training requirements but require a sign off by a qualified flight instructor saying that I am proficient to take the practical test. This is how I interpret the FAR since by definition adding Instrument-Helicopter is an additional class added to my airplane-instrument rating (class-helicopter, category-rotorcraft). The flight school that I am conducting my training out has always made it mandatory to conduct 15 hours of training with a CFII to comply with FAR 61.65 for the add-on. After posing this question to the flight school they are unsure what is "actually" required by the FAA.
 
If this is what is meant the difference is flying the amount of hours to make my instructor feel that I am proficient versus the 15 hours required by FAR 61.65 which could be a substantial difference in my wallet. I spoke with the General Aviation POI at our local FSDO and did not get a "warm-fuzzy" feeling that he understood my question.  His answer was to refer to the PTS, which is a great answer once all requirements are meant to fill out the IACRA form but does no good to get to that point.  Since I must do what the FAA requires it makes little difference how I understand the regulation but I was curious if anyone could shed some light on the subject or point me in a direction to help decipher what the FAA wants. Obviously, I want to prove to the FAA that I can safely operate an aircraft in instrument conditions but after 2.8 hours with my instructor she feels that I am proficient so I don't want to waste and additional 12.2 hours at $250 an hour.

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4 Answers



  1. Nathan Parker on Jan 09, 2012

    “since by definition adding Instrument-Helicopter is an additional class added to my airplane-instrument rating”
     
    An instrument rating isn’t a class or category rating and therefore 61.63 doesn’t apply.  A rating is applied to a pilot or instructor certificate, not another rating, and the instrument rating is category specific.  So you’re adding an instrument helicopter to your private certificate.
     
    My read is that you will be required to fully comply with 6165(e); however, the areas of operation are not category or class specific, unlike the requirements for pilot certificates, so it appears that much of your existing simulated time would count towards that, meaning that you only need 15 hours in a helicopter with a -II.  And you won’t have to take the knowledge test again.

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  2. Donald Vang on Jan 09, 2012

    So, if I am understanding correctly, the helicopter-instrument rating is not an add-on in the sense that adding helicopter-commercial to multi engine-commercial.  The instrument ratings are seperate a seperate certification for each (airplane, helicopter or powered lift) and are treated as such in regards to training, correct?  I guess what is confusing to me is that I am also adding single engine-commercial (rating) also and I am not required to fulfill the 3 hour night cross-country with a CFI because I already hold multi engine-commercial (the same will be the case when adding helicopter-commercial).  I guess the confusing part is really that I am over-analyzing the wording (helicopter-instrument being an additional aircraft class rating covered under FAR 61.63 (c) and rotorcraft-instrument, if it existed, would be an additional aircraft category rating covered under FAR 61.63 (b) being the category).  So, for future reference I should think of Private/Commercial/Instructor as licenses that I can add class/category ratings too (single engine, multi-engine, etc.) and the instrument rating for each class/category are added to those certificates?  I guess what it boils down to is that helicopter-instrument and airplane-instrument are completely seperate and all of the requirements need to be met in accordance with FAR 61.63 (b) and 61.65 (e). 

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  3. Nathan Parker on Jan 09, 2012

    “the helicopter-instrument rating is not an add-on in the sense that adding helicopter-commercial to multi engine-commercial.  ”
     
    Correct.  That scenario is a new category rating being added to your Commercial certificate.  You will note that 61.63 talks about adding class or category ratings to a pilot certificate.
     
    “instrument ratings are seperate a seperate certification for each (airplane, helicopter or powered lift) and are treated as such in regards to training, correct?  ”
     
    Yes.
     
    “I guess what is confusing to me is that I am also adding single engine-commercial (rating) also and I am not required to fulfill the 3 hour night cross-country with a CFI because I already hold multi engine-commercial (the same will be the case when adding helicopter-commercial). ”
     
    That scenario is adding a new class rating to your Commercial pilot certificate, also covered by 61.63.
     
    “So, for future reference I should think of Private/Commercial/Instructor as licenses that I can add class/category ratings too (single engine, multi-engine, etc.) and the instrument rating for each class/category are added to those certificates?  ”
     
    Bingo.
     
    “I guess what it boils down to is that helicopter-instrument and airplane-instrument are completely seperate and all of the requirements need to be met in accordance with FAR 61.63 (b) and 61.65 (e). ”
     
    Yes, except that 61.63(b) doesn’t apply, since you already have the category rating.
     
    Note that 61.63 doesn’t apply to instructor certificate add-ons either.  I suppose the logic is that the instrument rating requirements already has a means to escape redundant training by only requiring 15 hours in a helicopter, and instructor ratings don’t have minimum training requirements.
     
    I realize that all this stuff is a bit confusing; the FAA used to have something called “Part 61 FAQs” which elaborated on certificate/rating theory, as long as you were willing to read about 300 pages. 😉

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  4. Wes Beard on Jan 09, 2012

    Donald,
     
    §61.5 lists the certificates and ratings that you can place onto your pilot certificate.  Notice that the instrument (§61.5(b)(8)) has an instrument rating.  It is neither a category of class of airplane but an authorization to fly in IMC conditions.
     
    §61.65(e)(2) applies in your situation and you will need to have 15 hours with a Helo CFII.
     
    §61.63 has verbiage to add a new aircraft category and a new aircraft class rating.  If we go back to §61.5 we can all see that an instrument rating does not fall under either a category or class rating.

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